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E-Commerce Contracts and the clauses covered under it

By: Alok Rao

Introduction: –
E-commerce is a form of business model, or segments of a larger business model, enabling a company or person to conduct business on an electronic network, typically the Internet. However, there is no specific meaning of the term e-commerce, which is usually used to denote a form of doing business by electronic means rather than by conventional physical means. E-commerce questioned companies’ traditional system trading with customers, putting together diverse business models that empowered consumers.

The most popular business models facilitated by e-commerce are:

  1. B2B: Business to Business (B2B) explains trade transactions between different companies, allowing foreign companies to develop new partnerships with other companies. As between the manufacturer and the wholesaler, or between the wholesaler and the retailer.
  2. B2C: Business to Consumer (B2C) defines companies’ operations providing end customers with goods and/or services. There has always been a direct interaction between companies and customers, but with e-commerce, the traction has been gained in such transactions.
  3. C2C: Business to Consumer (C2C) includes electronically facilitated transactions between consumers through third parties. Traditionally, customers have had interactions with other consumers, but only a handful of these practises have been of a commercial sort.
  4. C2B: Customer to Business (C2B) involves customers supplying goods/services to businesses and generating value for the company.
  5. B2B2C: This is an alternative to the B2C model, and there is an external intermediary sector in this form of the model to assist the first business transaction with the end customer. For example, Flipkart is one of the popular e-commerce portals and offers a stage for customers to buy a wide variety of items, such as books, music, CDs, etc.

As a result, the e-commerce world may appear uncomplicated and economical; there are several legal considerations that an e-commerce company must seriously consider and bear in mind before beginning and while carrying out its operations.

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E-commerce law in India: –

Information Technology Act, 2000
The first ever e-commerce legislation passed by India’s Government was the Information Technology (IT) Act 2000. It was an act to give effect to the UNCITRAL Model Law on Electronic Commerce, 1996. On 30 January 1997, the General Assembly of the United Nations adopted a resolution commending the Model Law on Electronic Commerce for favourable consideration by the Member States as a Model Law as they pass or amend their rules, given the need for uniformity of the law applicable to alternatives to paper-based methods of communication and storage of information.

The IT Act’s primary purpose was to include legal recognition of transactions carried out through electronic data exchange and other electronic means of communication, generally referred to as electronic commerce (e-commerce). The IT Act 2000 facilitates e-commerce and e-government in the region. It includes guidelines on the legal recognition of electronic records and digital signatures rules for the allocation of e-records, the process and manner of reception, the time and place of dispatch and the receipt of electronic documents. The Act also sets out a legal system which sets out penalties for various cyber offences and crimes. Significantly, under the Act, the Certification Authority is the focal point around which this Act revolves, as most of the provisions relate to the Regulation of Certification Authorities, i.e., the appointment of a CA Controller, the licensing of CAs and the recognition of international CAs. It has also punished crimes such as hacking, damage to the source code of the machine, publication of information that is obscene in electronic form, violation of confidentiality and privacy, and fraudulent granting and use of digital signatures. It also provides civil liability, i.e., cyber contraventions and criminal infringements, fines, the establishment of the Adjudicating Authority and the Cyber Regulatory Appeal Tribunals.

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The relevant provisions of the Indian Panel Code, 1860, the Indian Evidence Act, 1872, the Banker’s Book Evidence Act, 1891 and the Reserve Bank of India Act, 1934 were also amended to resolve the related issues.

Information Technology (Amendment) Act, 2008
India incorporated the Information Technology (Amendment) Act, 2008 to apply the UNCITRAL Model Law on Electronic Signatures, 2001 in India. The IT Act of 2000 was modified to make it technologically neutral and accepted electronic signatures over-restrictive digital signatures. The Act incorporated several amendments, such as implementing the principle of e-signature, the modification of the definition of intermediary, etc. Also, the State asserted unique powers to monitor websites in order, on the one hand, to protect the privacy and, on the other hand, to control potential misuse leading to tax evasion. It is important to note that this Act acknowledged the legal validity and enforceability of digital signatures and electronic records for the first time in India and concentrated on protected digital signatures and secure electronic documents. These reforms were implemented to reduce the occurrence of electronic forgeries and promote e-commerce transactions.

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Legal Validity of Electronic Transactions in India: –
There are numerous legal concerns related to the formation and legality of electronic transactions, such as online contracts and compliance issues, which are dealt with below.
Formation of an E-Contract
The most popular types of e-contracts are clickwrap, search wrap and shrink wrap contracts. The terms and conditions of such agreements shall be made available to the contracting party in a manner which is substantially different from the standard paper contracts. By clicking on the wrap contract, the party’s affirmative approval is made by checking the ‘I agree’ tab with a scroll box that allows the acceptance party to access the terms and conditions.
In the case of a browser wrap arrangement, the website’s mere use (or browsing) makes the terms binding on the contracting party.
In a Shrink-wrap agreement, the contracting party can read the terms and conditions only after opening the box inside which the product (usually a licence) is packed. Such contracts are important in the context of e-commerce, primarily because of the form of products associated with shrink-wrap agreements.

Online Contract Validity
The Indian Contract Act, 1872, regulates all e-contracts in India, inter alia, mandate specific pre-requisites for a valid contract, such as free consent and legal consideration. The concern to be considered is how the Indian Contract Act’s specifications can be met with e-contracts. Also, the Information Technology Act, 2000 (‘IT Act’) enhances the legitimacy of e-contracts.
According to the Indian Contract Act, 1872, some of the essential specifications of a legal contract are as follows:

  • The agreement should be entered into with the free consent of the parties.
  • The agreement should be considered lawfully.
  • The parties should have the authority to enter into contracts.
  • The purpose of the contract is to be lawful.
  • Terms and conditions associated with the e-commerce platform are of the utmost importance in ensuring that the e-commerce agreement meets a legal contract’s specifications.

Unless expressly forbidden, clickwrap agreements would be enforceable and legal if the provisions of a valid contract set out in the Indian Contract Act of 1872 were met.

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There is no provision under the Indian Contract Act that written contracts be physically signed. However, the unique statuses do include the criteria for signature. Furthermore, the very essence of e-commerce is that it is virtually impossible to verify the age of someone who is trading online and who presents problems and liabilities to e-commerce platforms because the situation under Indian law is that a minor is not qualified to enter into a contract and that such an agreement is not enforceable against a minor.
In India, any instrument under which rights are produced or transferred must be stamped. The stamping of the instrument also depends on relevant stamp duty legislation passed by different states in India.

Standard Type of Online Contracts is not appropriate.
There is no well-developed case law in India as to whether the traditional type of online agreements is unwise. However, Indian courts have previously dealt with cases where contract terms, including common form contracts, have been negotiated between parties in unequal negotiating positions. Specific provisions of the Contract Act deal with unenforceable agreements, such as when public policy is opposed to considering the contract or subject-matter of the contract. The agreement itself cannot be valid in such situations.
The courts may place the individual’s responsibility in the leading position to show that the contract was not caused by undue influence.
In the case of ‘LIC India Vs. Consumer Education & Research Centre’
L.I.C. Of India & Anr vs Consumer Education & Research Centre & Ors. Etc. 1995 SCC (5) 482, the Hon’ble Apex Court of India interpreted the insurance policy issued by India’s Life Insurance Corporation by adding certain public interest elements. The court observed that ” in dotted line contracts there would be no occasion for the weaker party to bargain as to assume to have equal bargaining power. He has either to accept or leave the service or goods in terms of the dotted line contract. His option would be either to accept the unreasonable or unfair terms or forgo the service forever.”

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It is essential to provide well-thought-out terms that shape online contracts to ensure that there is an ample opportunity for consumers to familiarise themselves with the terms of such agreements. In addition to the above, there is also a range of other legal, tax and regulatory concerns, in particular Security Issues, Consumer Protection Issues, Intellectual Property Issues, Content Control, Intermediate Liability, Jurisdictional Issues and Tax Issues, which need to be taken into account when dealing with e-commerce transactions.

Conclusion: –
Rapid growth in e-commerce has generated the need for vibrant and efficient regulatory frameworks to reinforce the legal framework crucial to the success of e-commerce in India. It has always been argued that poor cybersecurity laws in India and the lack of a proper regulatory system for e-commerce are why both Indians and the e-commerce industry face so many challenges in enjoying a consumer-friendly and business-friendly e-commerce climate in India. India does not have any dedicated e-commerce regulatory legislation other than the IT Act that governs India’s e-commerce and transactions. Therefore, the government should create a legal structure for e-commerce so that domestic and foreign trade in India will flourish so that fundamental rights such as privacy, intellectual property, the prevention of fraud, consumer protection, and so on are taken care of. The legal community in India needs the required expertise to direct entrepreneurs, customers, and even courts. The rapidly evolving market module can comply with existing legislation usually applicable to business transactions in standard modules. Simultaneously, it should ensure that the benefits of technology are unhindered by the judicious evolution of law by the learned interpretation of the court, and there is still a consensus that specialized law governing and controlling some aspects of e-commerce is an obligation and an exclusive requirement.

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Software Licensing Agreements and the Clauses Covered Under it

By: Subham Saurabh

A software license agreement is an agreement/contract between a company and the user of that software who has the rights to use. It laydowns details for the users how to exactly run and use the particular software. The agreement tells a user how the software can be installed and what is the procedure to install it also how many times a user can install it. It additionally has clauses for the intellectual property rights (IPR) through which users know the copying, modifying and redistributing policy of the software. Thus, to prevent any kind of infringement of IPR a software owner needs to have a software license agreement with their customers.

The software license agreement does not have any particular format, the agreement differs as much as the software if there is a change in the software the agreement has to be changed. There is novation in the contract as soon as there is a software change. A software license agreement is important for both the licensor and the licensees along with the other stakeholders who have interest in the software as it lay downs the important clauses, jurisdiction, rights, modification, transferability etc. As an owner, a lot of money and time is being invested in developing the software and it is always in the mind of the developer that he could derive some monetary benefits out of it. If one individual is putting so much effort, he or she must put an effort to protect his or her IPR and other related rights. Here a software license agreement comes in the picture. Below are the reasons why to have a license agreement.

  1. It limits the liability: It is one of the most important parts of the agreement since if an owner did not limit his liability as to the software developer, then he is exposing himself for a lawsuit, people all the times are ready to file frivolous lawsuits and demand compensations for no real reason. Such lawsuits not only waste the money but also precious time. If a developer limits his liability though an agreement, he is ensuring the others from filing frivolous lawsuits as they have agreed to the software terms as soon as they buy it or in some case download it. Limiting liability can be from both sides.
  2. The agreement prevents others to sell it: Such an agreement with the customers restrict them to copy the software and redistribute it to others. There is also a huge difference between the developer licensing the software and not selling it. When the owner sells the software to a user, the owner still has all the rights also the owner can restrict the use. By this way, the developer/ owner has more control over the software in contract to the actual user of the software. For the long run and to derive more monitory benefit from the software the owner should not sell the rights of software rather license it.
  3. The license agreement allows the developer to terminate at any time: The owners have an extra advantage clause at their rescue which may state that owner can terminate the license at any period of use. The clause may also provide the owner to terminate it without providing any explanation. This is another important clause which helps the owners to maintain comprehensive control over the software at all times. At any time if licensor wishes to revoke the license and institute a suit instead, he can refer the licensee this particular clause.
  4. It avoids misappropriation of software: The hackers and such person who are always ready to make a replicate or a copy an individual’s intellect are always at the hurry to do it if the owner fails to have an agreement with the users. There is very less probability that others can sell the software however if a pirated version is circulated it would be a huge loss. A person would not buy the software if he is getting it for free and it will be unfair to the developer and owners.
  5. License agreement permits to disclaim warranties: Nothing can be in software, no matter what a developer do there is always an error with the technology it may be a bug, crash or downtime etc. and such errors allows a user to dissatisfactions. The license agreement may have clauses which would contain a disclaimer from such errors for which the user would eventually escape the liability.

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Main Section included in the Software License Agreement

Fundamentally, there are four primary sections for software license agreement and these four sections provide key information which is essential to the accomplishment of a software license agreement which is as follows:

  1. General Information – In the first section, we will get information about the execution of the agreement that when it will go into effect, for what duration of time the software will be active and what is the type of this agreement. This is the key part of any agreement although it provides general information because it sets the tone for the whole agreement.
  2. Parties Involved – This particular section provides information about the parties who are going to agree. When any person or company enters with the developer company or owner company of software the agreement must detail both the company or individual’s details. The full name and complete addresses and other key information should also be included in such agreement. Also, it is essential to state whether the party who is forming the agreement is a company or an individual.
  3. Terms of the agreement – This section includes all the other primary information regarding the terms of the agreement. Information such as price to be paid for using the software, information about the maintenance, support, warranty if any etc. will be listed which are offered by the software company. The other information that “whether you will be including the code along with the license and if it is a site license or not” is included.
  4. Fine details – The last section included all the miscellaneous details which are missed out in above three sections of the software license agreement. This section is drafted more carefully and according to the specific situation instead of wide clauses. At last, where the agreement is signed along with the dates are mentioned.

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Important Clauses of Software License Agreements

The above four-section provides the overview in brief of what features a user can assume from any general software license agreement. However, the company or developer to exclude its unsolicited liability and frivolous suits should include other key clauses which will guarantee their protection from liability in future also. It is important to include such clauses in the license agreement as the future is unpredictable and anything can happen, and from this unpredictable situation, the agreement must guarantee protection. Below is the list of such clauses:

  • Limitation of liability – It is one of the important clauses as it limits the software owner’s liability form uncertain future events. This clause laid down that the fact that the user should accept the software without any changes from the third party and they will not be able to claim any injury compensation, also it may be stated that no warranty could be claimed from the software and the usage.
  • Non-exclusivity –When a licensor wants to license the software to an individual or a company, he should make sure that the agreement has the clause that does not leave details that the rights of the licensee are non-exclusive. By providing such a clause in the agreement the software will the developers to stay longer in the market with the product and make a profit from the software.
  • Non-transferability – This is another important clause from the point of view of earning the profit. The non-transferability clause helps to restrict if the developer did not want the license to be transferred to another third party. If not restricted it will allow the licensee to transfer the software to any other person or even business that will amount to a loss of profit and future clients. Lastly, developers will not like to come in force in a situation where they have to deal with the agreement with such a party with whom they have not contracted with.
  • Rights – Every information that the right to the software will remain the property of the licensor even after execution of understanding will be included in this clause. This clause also includes the original programming, the name, the copyright, the trademarks rights, and all other intellectual property rights. Licensor does not want somebody else buying a permit to then steals any crucial information regarding the software and creates its monetary benefit. This is a significant consideration since it secures owner item from its users.
  • Modification Clause– If the developer does not permit the software to be novated in any capacity toward the back, then it should make that reasonable with a provision which states as much and subtleties what the expression ” modification ” signifies for this agreement. Except if this is what the software owner wants to occur, it will probably just purpose issues for them afterwards. The best option available is to the limit any modification, if not limit them. Because this is a software license agreement, this isn’t typically normal. Your users will probably comprehend that the product is made in that manner in which it is and will remain that way.
  • Breach of agreement – The owner has to incorporate a provision which expresses that on the off chance that any terms are not followed, at that point it will bring about a breach of agreement where a developer can renounce the agreement, therefore. The user does not want that breach of an agreement to happen, yet for the situation that it does, it ought to have this set up so it can assume back responsibility for the software product and better ensure it.
  • Number of Device-Based upon how the developer permits the software if the developer incorporates that the licensee is permitted to utilize the software on one single PC or numerous PCs in a similar area, for example, the corporate area. This keeps organizations from exploiting the software and attempt to need more at the price they paid. It is not common that all licensee will attempt to find a sneaky tricky path around, however in the case that they do, it is ensured that developer has this point by point so there is no doubt.
  • Terms of the end – this clause must be included in the agreement as if the developer or user need to end the understanding, this provision will detail the moves that must be made by the licensee or otherwise. This is by and large something like terminating the software on-site or uninstalling it from the gadget. Also, it to likewise incorporate that the software can be ended or terminated whenever and, in any capacity, whatsoever with no consequences.
  • Governing law – The last important clause which should be included in the details about the administering law for settling any disputes. No one wants to wind up in the Court that is far away from his state of location or is in another jurisdiction. Also, the last thing important is to ensure that this recorded as a written so that any court procedures will just occur in you’re the choice of jurisdiction.

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Role of Intellectual Property In Artificial Intelligence

By: Sweta Mishra

INTRODUCTION TO ARTIFICIAL INTELLIGENCE:

There has been a huge advancement in the sphere of technology and moreover, huge resources are being invested may it be by human beings/organisations into these advancements.  The term “Artificial Intelligence” was coined by John McCarthy in a conference in the year 1956 which meant “science and engineering of making machines-intelligent machines that can process and interpret language; mine and analyse data; and create artistic and original works”.[1]

British and United States Governments had invested huge amount of resources into AI during 1956 and 1980 and thus, it was considered as a golden period for the AI. In the first place, AI is attractive for information collection due to three factors- speed, scale and automation. The speed at which AI performs calculations is much faster than that of human analysts and can also be constantly improved by more hardware addition. AI is capable of using large data sets for analysis as well and is perhaps the only way in which big data is processed in a reasonable amount of time. Finally, the designed tasks can be carried out without supervision, which considerably improves the efficiency of analysis.

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Many consumer products have functions that make them susceptible to AI data use. In order to make the situation worse, people often ignore how much data they produce process or share with their software and devices and as we are increasingly dependent on digital technology in our daily lives, the potential for exploitation only increases. Voice-recognition and recognition of the face are two ways of recognising AI’s performance and these methods are capable of seriously compromising public anonymity. Moreover, AI can use sophisticated algorithms for machine learning to draw sensible data from non-sensitive data forms. AI not only carries out data collection tasks. The data can also be used as input to sort, classify, evaluate and grade people. AI can be further used for identifying, Tracking and monitoring individuals, whether on- the job, at home or in public plays across several devices. This allows to de-anonymize your personal information on the basis of inferences from other. This flushes the distinction that is to be maintained in accordance with present legislation between personal and non-personal data. Moreover, AI is used to make recipes, make designs for clothing purpose and also helps in making music. It is predicted that these AI and other machines may be considered as the creators and drivers of these unique innovations though, it is considered to be impossible in order to gain rights over such creations on behalf of AI and in this way, Intellectual property law’s role comes to action in case of Artificial Intelligence.

INTRODUCTION TO INTELLECTUAL PROPERTY:

The government grants every creation of an intellect certain exclusive right for its creation and the holder is able to protect his property that includes literature, music, symbols, brands, inventions and innovations for a certain period of time, preventing others from tampering it. These rights, included widely in the property rights, are known as Intellectual Property Rights. Starting with the Harappa civilization, the scavenged potteries had special marks that determined the maker’s ideology and ownership. In Germany, special privileges were given to the constructors of model mills to store grains. The establishment of the Paris convention from the evolvement of the Vienna exhibition led to the recognition of protection of Intellectual Property Rights. In India, the Act VI on protection of inventions of 1856 surpassed the British Patent Law of 1852. The latter was the basis of creation of the latter. Since then, there have been many modifications in the Act based on the necessity of making stricter rules for protection of creation of work. Act VI was modified into Act XV whereby, regulations were made to reconsider the 14year period granted to inventors for protection of their creations. In 1872, the Act was renamed into the Patents and Design Protection Act, followed by the Protection of Inventions Act, 1883 and The Inventions and Designs Act and The Indian Patens and Designs Act, in 1888 and 1911 respectively. The right to Intellectual Property is not a right provided for tangible objects but also for the mind considered as a property. Intellectual property can also be described as ‘knowledge goods’ which was mentioned in the case of Bayer Corporation v. Union of India and Others[2]. The main reason of providing laws to protect intellectual property by many countries is to promote designing and innovation to furnish the social and economic development. Intellectual property is broadly divided into two subsets, Copyright and industrial property. Copyright persists in original literary, musical and artistic works, cinematograph films, sound recording, etc. in India. Whereas industrial property specifically deals with inventions and creations of human mind which includes patents, trademarks, integrated circuits, geographical indications and protection against unfair competition.[3]

Conventions based on IPR:

In 1960, United International Bureaux for the Protection of Intellectual Property [Bureaux Internationaux Réunis pour la Protection de la Propriété Intellectually (BIRPI)], was shifted from Berne to Geneva for increasing awareness of protection of IPR and bringing it in the consideration of United Nations. Later, the name of the international organization United International Bureaux for the Protection of Intellectual Property was changed to World Intellectual Property organization (WIPO).[4]

WIPO was signed in Stockholm on July14, 1967 and came into force in 1970 with an amendment in 1979. The two main objectives of WIPO were to promote the protection of IPR worldwide and to ensure administrative cooperation among the intellectual property Unions established by the treaties that WIPO administers.[5] In 2002, WIPO organized a study regarding IPR on the Internet. The survey focused on the international aspects of the effect of Internet evolution on IPR rights and duties of related individuals and organizations. In the process, the techno-savvy world has reorganized the very basis of copyright jurisprudence, thereby shattering the basic laws pertaining to it. Hence, the survey explains about the need to adhere to the set legal rules and ensure that technology and Internet do not undermine the basic tenets of copyright and related rights. Berne Convention for the Protection of Literary and Artistic Works (1886).

The Berne convention is based three important principles:

  1. Works originated by an author in a particular state must be given the same protection in

each of the other contracting states.

  1. Protection must not be conditional upon compliance with any formality.
  2. If contracting State provides for a longer term of protection than the minimum prescribed by the Convention and the work ceases to be protected in the country of origin, protection may be denied once protection in the country of origin ceases.[6]

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RELATION BETWEEN INTELLECTUAL PROPERTY AND ARTIFICIAL INTELLIGENCE:

There has been a paradigm shift which is being experienced by AI in its theory application to commercial application.   According to the World Intellectual Property Organization (‘WIPO’), “early 340,000 patent families related to artificial intelligence [have been] published from 1960 until early 2018.”[7] The Copyright Law also tries in protection of the software codes which are an integral part of the AI programming. As a matter of fact, these AI algorithms which aren’t easy to be reversed are entitled to protection under the scope of trade secrets and thus the Trademark Law intends in protection of the names of such robots.

It is pertinent to mention here that the existing Intellectual Property rights affect the Artificial Intelligence in some way or other. IBM has the largest portfolio of AI patents with 8,290 patent applications, followed by Microsoft with 5,930 patent applications.[8] The creators/owners of original works not only intend to acquire Intellectual Property rights but also exploit such rights in the Artificial Intelligence mode of technologies. For instance, “the Chinese Academy of Science has between 2008 and 2016 transferred and transformed 7,000 IP assets (transfer, license, self-implementation, price-for-share, technology development and technical services) with a contract value of more than RMB12 billion”[9]. Therefore, it can be said that the Intellectual Property Law not only protects the inventions but also prevents exploitation of such rights in the inventions pertaining to AI. The invention needs to be novel and should be capable enough for industrial production in order to be patented under the existing laws and provisions of India.

The question of difficulty arises when the AI technologies and AI inventions start playing a role in creation of certain works. As seen earlier, Ais are playing a huge role in making recipes, designing of clothes etc and thus, it is being even more complicated and difficult to acquire rights to protect such works which are being invented by the Ais on their won and such works are even considered of the best quality than if being prepared by huma beings.  For instance- “In a related trend, an AI conceived and executed a masterpiece known as ‘The Next Rembrandt’ using huge set of raw data and deep-learning algorithms in 2017.”[10]

The human being usually puts his labour and skill and uses the abilities of AI in order to make certain data which are then put into the AI in order to invent on the basis of such data. Thus, it wouldn’t be justifiable if such human being is not being permitted to acquire rights under Intellectual Property Law in order to protect such inventions. Therefore, it wouldn’t act as an incentive in order to motivate such human being who created such inventions through the help of his own skill and AI’s learning abilities.

Thus, it can be concluded by saying that there are numerous questions which need to be answered after years regarding the actual meaning of “Author”, what comes under the purview of “Patentable”, who is an “Inventor”, liability in case of AIs hampering the IP rights of the human beings, status of ownership and whether AIs can be granted rights under the Patent Law when they become independent enough to invent things on their own without the help or efforts of human beings.

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[1] Meaning of Artificial Intelligence, http://jmc.stanford.edu/articles/whatisai.html

[2] Bayer Corporation v. Union of India and Others, 2014(5) ABR 242: MIPR 2014 (3) 53: 2014 (60) PTC 277

(Bom)

[3] “Intellectual, industrial and commercial property | Fact Sheets on the European Union | European Parliament” (September 17, 2019; 20:00 pm)

[4] “WIPO — A Brief History”. World Intellectual Property Organization (WIPO).

[5] Summaries of Conventions, Treaties and Agreements Administered by WIPO

[6] Supra 6

[7] Kathleen Walch, ‘Artificial Intelligence Is Not A Technology’, (2018) Available from: https://www.forbes.com/sites/cognitiveworld/2018/11/01/artificial-intelligence-is-not-a-technology/#7b4dc6645dcb, Accessed on 11th November, 2020 at 6:00 pm.

[8] Ibid, Pg. 58

[9] Ibid

[10] Kavita Iyer, ‘Google’s AI Creates Its Own AI That Is Superior Than The Ones Made By Humans’, (2017) Available from: https://www.techworm.net/2017/12/googles-ai-creates-ai-superior-ones-made-humans.html, Accessed on 12th November, 2020 at 8:00 am